The UK regulator which gave out the fines, the FCA (Financial Conduct Authority), spent ’45 man years on this investigation’, according to FCA enforcement director Tracey McDermott - but the regulator’s team relied heavily on interviews of bank staff conducted by lawyers in each of those banks. Some of the principle people involved in the Forex scandal were never interviewed by the FCA - but only by their own lawyer colleagues. 

Pragmatism

Brian Spiro of BCL Burton Copeland said: ‘If they can sub it out, get a speedy result and bring money into the coffers, it’s tempting to ask what more could you want. But some, myself included, ask: where does due process enter the equation? Do the enforcement agencies now operate within an environment solely governed by budget and pragmatism?’

Variations

One lawyer said that procedures for the in-house lawyers varied from bank to bank - as rules were not laid down consistently regarding note-taking and tape-recording. Source: Financial Times